Michigan v. Jackson (1985)
- Docket
- 84-1531
- Decided
- 1985-01-01
Summary
Question: When a defendant requests counsel at an arraignment, are the police allowed to initiate interrogations before that defendant has had a chance to consult with the appointed counsel? Conclusion: No. Justice John Paul Stevens delivered the opinion for the 6-3 majority. The Court held that the Fifth Amendment’s protection against self-incrimination and the Sixth Amendment’s guarantee of representation prevent the police from initiating an interrogation after a defendant has requested counsel. Therefore, unless the accused initiates the conversation, police are not allowed to ignore a request for counsel and begin an interrogation. The Court also held that the arraignment marks the beginning of the judicial process and the moment when the accused has a Sixth Amendment right to rely on counsel to act as “a ‘medium’ between him and the State.” From this point on, the suspect becomes the accused, and the assistance of counsel becomes essential. The Court rejected the state’s argument that the defendant’s request for counsel only applied to formal legal proceedings and noted that such a request is a “significant event” requiring additional attention and safeguards. If a defendant asks for counsel at an arraignment, any waiver of that right to counsel during police-initiated interrogations that may follow would be invalidated. Chief Justice Warren E. Burger authored a concurring opinion that warned of the dangers of using “hard cases” with difficult fact scenarios, such as these, to set “bright-line rules” for all cases. Justice William H. Rehnquist dissented and argued that the bright-line rule the majority opinion established should only apply to Fifth Amendment protection against self-incrimination and not Sixth Amendment rights. Justice Lewis F. Powell, Jr. and Justice Sandra Day O’Connor joined in the dissent.